Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Addition u/s 68 - unsecured loans Addition u/s 2(22)(e) - Deemed dividend - The Tribunal found merit in the Assessee's submissions, noting that all relevant documents were submitted to prove the legitimacy of the transaction. The addition under section 68 was reversed, and the AO was directed to delete the same. However, the addition under section 2(22)(e) was upheld, as the Assessee failed to provide substantial evidence to support the contention that the loan from M/s KAJ Infrastructure Pvt. Ltd. was for business purposes.
Addition u/s 68 - unsecured loans Addition u/s 2(22)(e) - Deemed dividend - The Tribunal found merit in the Assessee's submissions, noting that all relevant documents were submitted to prove the legitimacy of the transaction. The addition under section 68 was reversed, and the AO was directed to delete the same. However, the addition under section 2(22)(e) was upheld, as the Assessee failed to provide substantial evidence to support the contention that the loan from M/s KAJ Infrastructure Pvt. Ltd. was for business purposes.
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